Speak Up for Loons

 
 

September 8, 2025

DEC Proposal to remove Common Loons from the State Wildlife Action Plan for 2025-2035

ACLC Position: We would like to see Common Loons remain on the list as a Species of Greatest Conservation Need.

Action to take: Submit Public Comment By Sept. 20, 2025

Click Here to Submit a Public Comment

Information about the State Wildlife Action Plan (SWAP): 

The federal State Wildlife Grant Program aims to prevent wildlife species from being federally listed as threatened or endangered by implementing conservation actions before a species is in critical need. To qualify, New York State must update its conservation plans at least every 10 years in the form of a State Wildlife Action Plan (SWAP). The SWAP describes a state’s plan to conserve rare, declining, or at-risk species and seeks to highlight actions that will conserve biodiversity, improve coordination between conservation partners, and inform and engage the public. 

 The New York State Department of Environmental Conservation (DEC) has recently put out the draft for the 2025-2035 SWAP, in which the Common Loon is up for removal from its listing as a Species of Greatest Conservation Need (SGCN). There is a public comment period open until September 20th. 

Many species that have been removed from the SGCN listing in this draft, such as the Common Loon, were removed because they have apparently stable populations. 

 Loons are still listed as a Species of Special Concern in New York State, which will not change as a result of the proposed SWAP revision. Being listed as a Species of Greatest Conservation Need does not provide loons with any additional protections beyond what they already have under their listing as Special Concern.  

ACLC Response:

The Adirondack Center for Loon Conservation (ACLC) believes that loons should remain listed as a Species of Greatest Conservation Need (SGCN) in New York State. Some of our considerations on this matter include:

  • Despite recovery from historically low numbers in recent decades, loons have clearly identified threats to their reproductive success and survival in New York State which may place their long-term viability or persistence in New York in jeopardy. Loon reproductive success is declining in the Adirondack Park, with hatching success of nesting pairs appearing to be the driving factor of this decline. Loons in New York State are a model species which needs conservation actions and protections to prevent them from being listed as Threatened or Endangered in the future. 

  • Loons in the northeastern United States are projected to be one of the most affected species by climate change, which will lower loon reproductive success through increased nest flooding as a result of more frequent and intense rain events. Adirondack loons are at the southern edge of the species’ geographical range, and so we must get ahead of the threat of climate change to help prevent future range retraction. 

  • Loons are threatened by the following Conservation Measures Partnership (CMP) Threat Categories listed in the SWAP revision: 

    • 1. Residential and Commercial Development (such as shoreline development) 

    • 5. Biological Resource Use (such as fishing line entanglement and lead poisoning) 

    • 6. Human Intrusions & Disturbance (such as human disturbance of sensitive nest sites) 

    • 7. Natural System Modifications (such as dam management flooding loon nests) 

    • 8. Invasive & Other Problematic Species, Genes and Diseases (such as Avian Malaria) 

    • 9. Pollution (such as mercury) 

    • 11. Climate Change (such as nest flooding as a result of torrential rain events) 

  •  New York loons would benefit from the following Conservation Action Goals highlighted in the SWAP revision: 

    • Protect adequate and viable habitats for SGCN 

    • Manage and restore habitats to benefit SGCN 

    • Protect SGCN populations to reverse declines in abundance or loss of range 

    • Develop and maintain current monitoring data on SGCN abundance, distribution and condition 

  • Productivity of common loons in New York is listed as a proposed indicator of the health of lakes and ponds in the state. Loon productivity appears to be declining in New York State, which warrants further investigation of loon population trends and the health of our aquatic ecosystems. 

  • Loons are a K-selected species with a naturally low reproductive rate. Even if the population is currently stable, a further decline in reproductive success from 2025-2035 could lead to a population decline from lack of recruitment that could be difficult to recover from with intensifying climate change.  

  • Adult survival rate is very important to maintaining a viable breeding population of loons. Lead poisoning as a result of ingestion of lead fishing tackle continues to be a leading but preventable cause of death for adult loons in New York State. Current legislation is not effective at preventing lead tackle mortalities of loons in New York State, which can have population-level impacts. The status of a Species of Greatest Conservation Need could help pass more effective legislation for lead tackle, which would benefit other species and aquatic ecosystems in general. If loons are de-listed, it could be much harder to convince legislators to protect loons from the threat of lead fishing tackle.